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The European Commission is seeking to loosen or completely eliminate the need to remove hydrocarbons from waste electrical equipment, which up until now was part of the WEEE Directive.

The RAL Quality Assurance Association (QAA) has written to Stavros Dimas, the EU commissioner for the environment, criticising the commission’s plans and explaining that the proposed changes would have a negative impact on the environment and on climate-protection goals.

In December 2008, the European Commission published its proposed amendments to the WEEE Directive.

At the time, the RAL QAA welcomed the fact that these proposals contained no changes to the directive requirements regarding the treatment of waste refrigeration appliances that contain hydrocarbons.

However, RAL was astonished to learn that attempts are now being made to use the Technical Adaptation Committee (TAC), which meets in closed session, to completely eliminate the need to remove hydrocarbons from waste refrigeration equipment.

A commission document that was sent to the members of the TAC for discussion in December 2008 contained the following passage: ‘The following items could be considered to be deleted from Annex II: hydrocarbons – as they have a global warming potential below 15, for which extraction and treatment would not be environmentally beneficial.’ From a scientific point of view, the commission’s proposal is unacceptable and should be rejected.

While the RAL QAA can point to a wealth of scientific studies that back up its position, so far no scientific evidence has been presented to support or even justify deleting hydrocarbons from Annex II.

It is remarkable the commission has presented substantial amounts of evidence to support all other proposed changes (for example evidence of low collection rates to support its proposal for higher collection rates), but that in the case of hydrocarbons, no viable evidence, not even in studies ordered in the EU WEEE review process, has been provided that would support the deletion of hydrocarbons from Annex II.

It therefore seems that there are no tangible reasons in support of the proposed change other than the vested interests of certain appliance manufacturers.

The arguments presented by the RAL QAA to the commissioner for the environment can be summarised as follows: In the opinion of the RAL QAA, the obligation to remove hydrocarbons from waste electrical equipment (in particular waste refrigeration equipment), which up until now has been specified in Annex II to the WEEE Directive, must be retained.

Eliminating hydrocarbons from the requirements catalogue would have far-reaching consequences for environmental and climate-protection goals.

Furthermore, the joint processing of hydrocarbon-containing and CFC-containing refrigeration appliances should be declared as the generally accepted state-of-the-art in fridge recycling.

The pre-sorting of waste refrigeration appliances must be prohibited, as perfect separation of HC and CFC appliances is simply unattainable in practice.

As some of the hydrocarbons contained in refrigeration appliances (specifically the cyclopentanes) are classified as fluids, any amendment of Annex II (at least in the case of cyclopentanes) would not be possible without a corresponding change to the provision in the main body of the directive that requires the removal of all fluids from waste electrical and electronic equipment.

The passage in Annex II concerning the removal of hydrocarbons from WEEE cannot, in the opinion of RAL QAA, be deleted without changing the requirement to remove all fluids.

Without wishing to question the decision-making powers of the TAC, RAL QAA believes that for this reason alone, the issue of how hydrocarbons should be dealt with does not fall solely within the jurisdiction of the TAC.

The RAL QAA hopes that a majority of members of the TAC will back the position taken by Germany, Luxembourg and Austria.

These member states have each signaled in the WEEE review procedure that the requirement to remove hydrocarbons from waste electrical and electronic equipment should be retained as part of Annex II to the WEEE Directive and that the joint processing of all types of waste refrigeration appliances is justified on environmental grounds.

RAL: Quality Assurance Association

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